### Facts:
1. **Election Protest Initiation**:
– Emilio V. Reyes protested against the election of Apolonio R. Diaz, disputing the validity of certain ballots.
2. **Procedural Posture**:
– The trial court adjudicated the protest and counted the ballots in favor of both parties. Reyes contended that some ballots adjudicated to him were valid despite not being challenged by Diaz.
– Diaz raised an issue concerning the jurisdiction of the trial court in dealing with unchallenged ballots and the evidential sufficiency regarding Reyes’s certificate of candidacy.
3. **Court of Appeals**:
– The case was elevated to the Court of Appeals, which certified the case to the Supreme Court on the ground of jurisdictional issues.
### Issues:
1. **Jurisdiction of the Trial Court**:
– Whether the trial court had jurisdiction to adjudicate the election protest, given the procedural and evidentiary circumstances concerning Reyes’s certificate of candidacy.
– Whether the trial court had the authority to consider the validity of ballots not specifically challenged by Diaz in his counter-protest.
### Court’s Decision:
1. **Jurisdiction over Subject-Matter**:
– The Supreme Court clarified that subject-matter jurisdiction is conferred by law, not by intricacies of procedural facts. The Supreme Court reviewed whether the trial court had the jurisdiction to hear election protest based on filing of candidacy.
– The Court established that jurisdiction as used in the constitution and statutes refers to jurisdiction over the subject-matter, which is central to conferring appellate power to the Supreme Court. Minor procedural facts or interpretation of pleadings do not implicate jurisdiction over the subject-matter.
2. **Jurisdiction over the Issue**:
– The Court differentiated between jurisdiction over subject-matter (conferred by law) and jurisdiction over the issue (derived from pleadings and party consent). It asserted that trail courts require jurisdiction over both to validly try a case, but only jurisdiction over subject-matter is non-waivable and immutable.
– On the point of unchallenged ballots’ validity, the Court held that such examination falls within the trial court’s authority in the wider public interest of determining the legality of votes cast. The Court referenced previous rulings allowing courts to review all ballots.
### Doctrine:
– **Jurisdiction**:
– Defined as the court’s authority granted by a sovereign entity to hear matters of a general class.
– **Subject-Matter Jurisdiction**: Non-waivable, conferred by law, pivotal in maintaining judicial structure.
– **Jurisdiction over the Issue**: Conferred by pleadings, parties’ express or implied consent, distinct from subject-matter jurisdiction.
– **Public Interest in Suffrage**:
– Elective process integrity and public interest can necessitate judicial intervention beyond the specific procedural contentions of parties.
– Courts may adjudicate the legality of all ballots, even when not challenged explicitly by opposing parties.
### Class Notes:
– **Elements of Jurisdiction**:
– **Subject-Matter Jurisdiction**: Rooted in legal statutes, essential for the validity of judicial decisions.
– **Jurisdiction over Persons**: Derived from due process, ensures parties are rightly engaged.
– **Jurisdiction over Issues**: Mandate to address only pleaded or acknowledged issues unless party consent exists.
– **Relevant Law Provisions**:
– *Article VIII, Section 2, No. 3 of the 1935 Constitution*: Supreme Court jurisdiction over trial court jurisdiction issues.
– *Revised Administrative Code Section 138, No. 3*: Appellate jurisdiction detail.
### Historical Background:
– **Elective Disputes in 1940s Philippines**:
– Post-Commonwealth establishment, electoral disputes and the judicial interpretation of electoral laws were critical in stabilizing democratic processes.
– The case highlights the judiciary’s role in safeguarding electoral integrity during formative democratic years of the Philippines.
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